BETH HIRST: Good afternoon, everyone, my name is Beth Hirst, and I work for the National Federation of the Blind. I would like to request that only the active speakers have their video on. This way it would be easier for the other participants to view the interpreter. And my second announcement would be, at 10 minutes prior to the end of the workshop, I would make an announcement to let you know that there is 10 minutes remaining. If there's anything else you need, hop in chat, see if I can help with anything. Otherwise, enjoy yourselves. Thank you very much.
SHIRA GORDON: Good afternoon, everyone. I'm Shira Gordon. I'm an attorney at the U.S. Department of HUD Housing and Urban Development in the Office of General Counsel, in the Office of Fair Housing and Compliance. I am a white woman with brown hair and glasses, and I'm presenting from my apartment in Silver Spring. My presentation is on HUD’s Use of the Administrative Law Process to Enforce Disability Rights in Public and Assisted Housing.
If anyone has any questions or if there's anything in particular you are interested in hearing about, put that in the chat, or you can unmute yourself in you prefer. Otherwise I'll start in with it.
Today, I'm going to provide an overview of disability rights that my office works on, starting with an overview of Section 504 and the ADA, and then discussing how investigations are handled at HUD. Some cases that we've worked on, regulations that HUD is hoping to update, and information about HUD programs, some of which are specific to individuals with disabilities.
The statutes that my office works on include Title VI of the Civil Rights Act of 1964, Fair Housing Act, which is also Title VIII of the Civil Rights Act, Section 504 of the Rehabilitation Act, and the Age Discrimination Act. We work on cases in DC and around the country and serve as counsel overall. I mainly work on Section 504, Title VI, and the ADA, and today I'm mainly going to discuss Section 504 and the ADA, but I'll also discuss the Fair Housing Act as well. The Fair Housing Act, Section 504, and ADA, all have the same definition of disability, which is an actual physical or mental impairment that substantially limits one or more major life activities or major bodily functions. The second prong is having a record of such an impairment. And the third prong is being regarded as having such an impairment. Section 504 prohibits discrimination based on disability in the programs and activities and facilities of recipients of federal financial assistance. Section 504 also applies to sub recipients in addition to recipients. For example, if a housing operator such as a project-based voucher, owner or operator, receives money from a public housing authority, which receives money from HUD, that housing provider would also be covered by Section 504 in addition to the public housing authority itself. Generally, Section 504 has some greater and different requirements and procedures than the Fair Housing Act.
Title II of the ADA covers all public entities, which include the services, programs, and activities of state or local governments, agencies, and their instrumentalities.
Section 504 and the ADA apply to HUD funding that is not just for housing, whereas the Fair Housing Act only applies to the housing itself. For example, a public housing authority's office space would be covered by the ADA, whereas the Fair Housing Act wouldn't apply to it.
I'm now going to discuss reasonable accommodations and modifications. Under the Fair Housing Act, accommodations are adjustment, changes, in rules, policies, practices, or services, when necessary to afford the individuals with disabilities equal opportunity, and a reasonable modification refers to structural changes of existing premises that are occupied, or will be occupied, by an individual with a disability so that person can enjoy full benefits of the space they're living in.
Under Section 504, reasonable accommodations refer both to the changes, adaptations, or modifications to the policies and programs. They also refer to the structural changes to a person's dwelling unit or public or counties, areas where they live.
HUD Section 504 regulation uses the term "housing adjustments" to refer to reasonable accommodations.
Under the ADA, the regulations use the term "reasonable modifications" to refer to changes in policies, practices, and procedures, and -- but basically they're the same meaning, that the reasonable accommodations under the ADA also refer to structural modifications.
Here's some practice tips about reasonable accommodations and applications. A request for an accommodation or modification can be made orally or in writing by an applicant, tenant, or family member, someone acting on behalf of the individual with a disability. Magic words like "accommodation" or "modification" don't have to be used in order to make the request for one.
The request can be made at any time. You know, before someone is in a building, after they've been there for a long time. That doesn't matter. A housing provider can only ask for documentation or information about a disability, or a disability-related need for an accommodation. If it isn't obvious or already known by the housing provider.
The reasonable accommodation must be granted unless the accommodation would impose an undue financial and administrative burden or a fundamental alteration of the essential nature of the housing provider's operations.
If a reasonable accommodation is not provided, the housing provider needs to engage in an interactive process in order to provide a reasonable accommodation that would not result in an undue financial and administrative burden, or constitute a fundamental alteration.
If the housing provider doesn't have enough information to make a decision, if they don't know about the disability, or the disability-related need related to the accommodation or it's not clear what the accommodation seeker seeks, they need to engage in the interactive process. The person with a disability requesting the accommodation would be the best positioned to know his or her need.
Now I'm going to turn to physical accessibility to buildings. Most buildings that receive federal funding are covered by more than one federal accessibility law.
The Fair Housing Act applies to covered multifamily dwellings defined and constructed for occupancy under 1991. The Fair Housing Act regulation lists certain required accessible elements, including that doors be wide enough for a wheelchair, and that bathroom walls need to be reinforced so that grab bars can be installed.
The regulation lists 11 accessibility standards that are safe harbors in order to comply with the Fair Housing Act.
For Section 504, accessibility requirements apply to the design, construction, and alterations of federally assisted multifamily housing since 1988. Unlike the Fair Housing Act, there are program, access, and continuing obligation requirements. So even if the building was built before 1988, or if it was originally built without federal financial assistance, the owner is obligated to bring the building into compliance.
For program access, under both Section 504 and the ADA, the housing provider needs to operate the program so that when viewed in its entirety, it's ready accessible to and usable by individuals with disabilities. In larger programs like public housing, generally speaking, the public housing authority needs to bring the buildings into compliance under Section 504 and the ADA. Similar to the reasonable accommodation analysis, a recipient of federal funding does not need to undertake actions or make physical changes that would result in a fundamental alteration of the nature of a program or activity or would constitute an undue financial or administrative burden.
Housing authorities are also required to undergo a need assessment and transition plan in order to analyze what needs to be done to bring their buildings into compliance. Housing authorities must include individuals with disabilities in the most integrated setting appropriate, in terms of both their housing and their non-housing programs.
For the Americans with Disabilities Act, it applies to new construction and alterations since 1992, similarly to Section 504, there are program access and continuing obligation requirements. The accessibility standards under Section 504 of the ADA are generally higher than the Fair Housing Act requirements. The Architectural Barriers Act applies to federal and federally funded buildings, which must be developed, constructed, and/or altered to ensure accessibility.
I'm now going to take a little bit more about the physical accessibility requirements under Section 504. The accessibility standard is the Uniform Federal Accessibility Standards, UFAS, and there are a few exceptions noted in 504 where UFAS or Fair Housing Act require higher standards
For new multifamily quelling units, they need to be built to be accessible for individuals with disabilities. At least 5% of the units need to be accessible for individuals with mobility disabilities. An additional 2% need to be accessible for individuals with vision or hearing impairments. That includes things like visual doorbells for individuals who have hearing disabilities.
Also, all common areas and routes need to be accessible.
HUD can require a higher percentage than the 5%/2% if there is a greater need for accessible units.
For existing housing projects, if a substantial operation happens, which is if the alterations cost 75% or more of their replacement costs of the building, then the new construction requirements apply. For other alterations that don't rise to the level of substantial alterations, then those alterations must still be -- the alterations themselves need to be accessible, even if full compliance isn't reached. But until you get to 5% and 2% required.
Section 504 also has requirements for occupancy of the accessible units and requirements so that the accessible units are tenanted with individuals whose need match the accessibility features. Accessible units must also be distributed throughout the housing development so that people have a choice of bedroom sizes and locations of where they want to live, and are living in an integrated setting with a variety of people.
There are also requirements relating to the housing choice voucher program, which is also known as Section 8, which is where someone receives funding from a federal housing authority, but chooses where -- I just saw a comment that the audio is cutting out. I'll try using headphones if that might help.
Okay, well, let me know if you have any trouble hearing.
So for the housing choice voucher program, someone isn't being provided a specific unit by a public housing authority, but they -- the housing authority has the obligation to help tenants find an accessible unit and need to pay a higher rent in order to afford a more modern unit that meet the accessibility needs of the individual.
Okay, I'll try to speak up, and speak clearly. Hopefully people can hear me!
I'm now going to turn to effective communication requirements, housing providers covered by Section 504 and the Americans with Disabilities Act have an affirmative obligation to take appropriate steps to ensure effective communication. This is a continuing obligation. It's distinct from the reasonable accommodation framework.
Housing providers ensure effective communication by using appropriate auxiliary aids and services. Unlike physical accessibility requirements, which includes specific requirements for units, common areas, and routes, effective communication is a framework for analyzing what steps the recipient should take. So it's an individualized process to bring out which services to provide. Auxiliary aids and services include readers, braille materials, audio recordings, telephone amplifiers, telephones compatible with hearing aids, interpreters, notetakers, written materials, open and closed captioning. They also include accessible electronic and other technology, so websites, other technology, must be accessible.
And so, in determining which auxiliary aids to provide, the recipient must give primary consideration to the requests of the individual with a disability.
Section 508 of the Rehabilitation Act requires that digital and information technology procured and maintained by the entity must be accessible. So it applies to the government, but it's similar to the requirements for accessibility under Section 504 and the ADA. If a housing provider is not covered by Section 504 or the ADA, they still have an obligation to provide effective communication as a reasonable accommodation under the Fair Housing Act.
I'm now going to discuss HUD's administrative process, starting with a discussion of the investigation process and findings. For Section 504, HUD is required to make an investigation whenever there's compliance review, complaint, or other information indicating that a grantee is failing to comply to Section 504. So the investigation can be based on a client from an individual or an organization, or it can be a compliance review where HUD decides to generally look at the practices or physical accessibility of a grantee.
This is different from the Fair Housing Act, where cases are generally based on complaints, and HUD can only initiate a fair housing investigation without a complainant if it's a separate initiated investigation.
The investigation can include information requests that the housing provider, you know, provides data or information. It can include interviews with the housing provider employees, with tenants who live there, and it can also be physical surveys to see if the property is complying with the physical accessibility requirements.
The regulations require that a HUD grantee provide access and information. It talks about physical access to properties, but a lot of this has happened virtually, and especially during the pandemic. So, after HUD has completed the investigation, it issues a letter of findings, either finding that the grantee is not in compliance, or finding compliance. And this is both under Section 504 and the ADA. There is a right for review, where either a complainant or a grantee can say that it dis agrees with the findings, and then HUD issues a letter of determination where it can modify or change the findings it made before.
I don't know if people can hear me better or worse than when I wasn't using microphones, but let me know if you're still having trouble.
And, so, now turning to the next stages of the process, which are the relief and enforcement steps. So, either before or after a letter of findings is issued, HUD can enter into a voluntary compliance agreement under Section 504 or the ADA with a grantee. It's a two-party negotiation between HUD and the grantee, or recipient. Whereas under the Fair Housing Act, it's a three-party negotiation between the complainant, a respondent, and HUD.
Relief can include being in the public interest, monetary victim compensation, it can include changes to policies, physical modifications, or other relief.
If a VCA negotiation isn't successful, HUD can seek other relief by terminating federal financial assistance, debarment, where the grantee can no longer participate in HUD programs or special assurances. Another possibility is that after a letter of findings is issued, if the letter of findings found that there were systemic violations or if there were charges under the fair housing Act, grantee is ineligible for notices of funding opportunity. So this doesn't cut off current funding that's been obligated, but it means that future funds or future funding competitions can't be made. So basically, outstanding civil rights matters need to be resolved before somebody applies for these types of funds.
Another enforcement option is referring a case to the Justice Department, and the Justice Department can then file a complaint to the federal court to seek enforcement that way.
The procedure is a little bit different under the Fair Housing Act, where if conciliation doesn't occur, then HUD issues a determination of cause and a charge of discrimination. The complainant or the respondent can decide to have the case tried in federal district court, in which case the Justice Department handles the case. Or if it stays at HUD, an administrative law judge hears the case.
I'm now going to discuss a couple of cases that my office has worked on recently, starting with Carbrook, which is a case that I worked on. HUD originally began an investigation after receiving a complaint from an African American woman who alleged that the property on her floor had not maintained her unit, while maintaining the units of white tenants. HUD -- the case also involved race discrimination, but I'm just going to discuss the disability issues. The Carbrook properties were 81 project based rental assistance units in two buildings in Brooklyn, New York. They were constructed in the 1970s, so before the Fair Housing Act and Section 504 requirements existed. They were owned by Carbrook since 1981, and Carbrook received millions of dollars from HUD between 1981 and 2021.
HUD's investigation began in 2018, and found accessibility barriers including steps in the lobby, an inaccessible route, and that there were no accessible units. We also found that there had been enough renovations that the buildings should have come into compliance with Section 504 and under the program access requirements.
In 2019, HUD issued a letter of findings and a letter of determination. The voluntary compliance agreement negotiations were unsuccessful. Carbrook did not understand the Section 504 process and believed there had not been alterations that required accessible units. We also learned that Carbrook was leaving the project rental assistance program in October of 2021.
We issued an enforcement letter in April of 2021 notifying Carbrook that HUD would terminate or suspend Carbrook's funding because it had not entered into a voluntary compliance agreement. Carbrook had the option of complying with the voluntary compliance agreement, asking for a hearing, or agreeing that the funding would be terminated. Carbrook requested a hearing, and we issued a notice of proposed adverse action, which is equivalent to a charge of complaint. The hearing in front of the administrative law judge was set for October of 2021, and we suspended Carbrook's payment in June. As far as we know, this was the first time HUD had issued a notice of proposed adverse action and had suspended funding under Section 504. We began discovery, and including notice and deposition, and in June of 2021, we entered into a consent order in which Carbrook agreed to retrofit 5% and 2% of its units for the mobility and vision care units, and remediate the inaccessible routes. They also agreed to hire an independent licensed architect would who help them with compliance. And the administrative law judge and HUD secretary signed it.
After the contract for the project-based rental assistance units terminated, there was an AVB transfer where that assistance was transferred to a different property in Baltimore, and then HUD is working with the tenants to ensure that they receive tenant-based vouchers if they needed it.
I'm now going to turn to the Housing Authority of Prince George's County case in Maryland. I see that someone from Maryland is on the call, and we worked with him as well on this. So this was a case I worked on, HUD became involved, after Disability Rights Maryland had filed a lawsuit alleging that tenants had not been provided accessible units, and were sometimes given housing choice vouchers, but were not given sufficient assistance finding accessible units. And they had not been provided reasonable accommodations. This included tenants using wheelchairs as well as a tenant who was Deaf. The compliance review was initiated in 2017 under Section 504 and the ADA, because most of their properties were too old to be covered by the Fair Housing Act. We did onsite reviews where we did measurements of units and common areas and spoke with employees of the housing authority as well as tenants. We found a lack of accessibility throughout the housing programs, including public housing, rehabilitation, vouchers, and the housing choice voucher programs, and found that the housing authority failed to respond to tenants' reasonable accommodations requests. We were able to enter into a voluntary compliance agreement, and that was before -- we didn't need to issue a letter of findings because we were able to reach the VCA before that.
The VCA required that the housing authority bring the public housing and voucher-based programs into compliance by making at least 5% of the units mobility accessible and at least 2% vision accessible, and to hire independent licensed architects to evaluate and design accessible retrofitting of the existing units and common areas, and work with disability rights organizations to recruit landlords with accessible units into the housing choice voucher program.
In accordance with the settlement agreement that Disability Rights Maryland entered into in Ripley v Housing Authority of Prince George's County, the housing authority had to create a $200,000 modification fund to pay the costs for tenants in the housing choice voucher program who needed reasonable accommodations and modifications. It also required a compensation fund for tenants who had been denied reasonable accommodations. There were also requirements to develop policies for nondiscrimination and accessibility, reasonable accommodations, effective communication, transfers, and assistance animals.
I'm now going to discuss a couple of other cases that other people in my office have worked on. One is Brown v Richmond Redevelopment and Housing Authority in 2022, so, very recently, HUD issued a letter of findings finding that the Richmond Housing Authority failed to ensure effective communication and provide reasonable accommodations.
Ms. Brown had requested a hearing-accessible unit between 2016 and 2017. The housing authority did not respond. Eventually in 2018, they installed smoke detectors with flashing lights, but Ms. Brown also requested a bed shaker and a visual doorbell, which they had not installed, I believe. In 2017, she asked for an additional lock and door alarm because her son had autism and ADHD and had escaped from the housing unit. The housing authority said she needed to purchase it herself, which she did. And the housing authority also didn't communicate effectively by not providing a translator.
For the Atlanta Housing Authority, in 2021, HUD issued a letter of findings and a letter of determination finding that the housing authority had violated Section 504 and the ADA by failing to ensure that subrecipients provided reasonable accommodations and modifications. They had failed to effectuate reasonable accommodation and reasonable modification requests, had failed to maintain records, and had denied or delayed responses to reasonable accommodation requests.
The Atlanta Housing Authority along with the owners of managed public housing, voucher-based public housing authority, but the complaint was against the housing authority because they still had the obligation under Section 504 and the ADA to ensure that the property owners provide the reasonable accommodations to tenants.
The letter of findings listed 15 tenants as examples of tenants whose reasonable accommodations had been delayed or denied, such as requests for grab bars, accessible spaces, two-bedroom units so that the tenant could have a live-in aide, and requests for unit transfers.
The Johnson v Dallas Housing Authority case, in 2021, HUD issued a letter of findings and a letter of determination, because the housing authority had failed to implement Ms. Johnson's reasonable accommodation request. Ms. Johnson was in a car crash and used a wheelchair, and she was living in a unit on the second floor. She had to crawl up and down the stairs in order to get to her unit. And at one point, she fell, resulting in an injury to her chest and she needed to be hospitalized.
The housing authority granted Ms. Johnson's request for a transfer, but didn't transfer her because the housing authority was in the process of trying to evict her, and I think the housing authority was afraid that it would slow down the eviction proceedings if they attempted to evict her.
And this is a case that is under the Fair Housing Act as well as being under Section 504 and the ADA.
Finally, for the Bridgeport Housing Authority, in 2019, the U.S. Department of Justice reached a $1.5 million settlement agreement with the housing authority following a compliance review by HUD. The investigation was based on a failure to provide accessible units and respond to reasonable accommodation requests.
The City of Los Angeles was another big case. It was against -- it was about the city's affordable housing program, whereas most of the cases I've talked about have been public housing authorities. This case started in 2011 with a compliance review, and then in 2012, HUD issued a letter of findings of noncompliance, and determination of noncompliance. In 2017 HUD did an onsite review again and issued another letter of findings. HUD found widespread accessibility violations, both in dwelling units and in public and common areas. In 2019, HUD and the City of Los Angeles executed a 10-year voluntary compliance agreement. It required a higher percentage of accessible units, so 11% mobility accessible units and 4% vision and hearing units, as opposed to the normal 5% and 2%. And it required that 3100 units be retrofitted. It included some super-accessible units, units with requirements above the normal UFAS and other accessibility standards. It also required policies and procedures to be listed on the website.
I'll now turn to HUD's regulatory agenda. There are a couple of regulations listed on HUD's agenda, regulatory agenda that was published in fall of 2021. These are changes that HUD is hoping to make to existing recommendations.
HUD's Section 504 regulations were issued in 1988, so HUD will seek comments on ways it can improve the regulations, to both the regulations and the accessibility standards, which, as I've discussed, are UFAS and the Architectural Barriers Act standards. Reasons for updating these regulations include innovations in technology and changes in housing.
For the Fair Housing Act, HUD will consider whether to adopt a standard -- so as I discussed, currently, there are safe harbors listed, where housing providers have a choice of different ways that they can comply with the Fair Housing Act, but HUD is considering whether to adopt a national standard for accessibility.
The Architectural Barriers Act, similarly to Section 504, this standard is UFAS or using the 2010 alerts with the deeming notice. So HUD is considering updating UFAS.
For Affirmatively Furthering Fair Housing regulation, in June of 2021, HUD issued an interim final goal which restored certain parts of the 2015AFFH regulation, but HUD is also considering publishing an advanced notice of proposed rulemaking or notice of proposed rulemaking with a more extensive AFFH regulation. So basically, what happens is HUD would issue either an advance notice of proposed rulemaking or a notice of proposed rulemaking, and then there's an opportunity for public comment, and we would want to receive a wide range of public comments about ways that these regulations can be updated or clarified.
So, finally, I'm going to talk about some of HUD's programs. There are some programs that are specifically housing for individuals with disabilities. They include Housing Opportunities for Persons with AIDS, or HOPWA, and Section 811 program, which is supportive housing for persons with disabilities. Section 811 provides subsidies to nonprofit developers, affordable housing and assistance to state housing agencies. Even though supportive services are provided, residents are not required to participate in the services.
Section 811 also provides vouchers, and so these are housing choice vouchers where an individual has a choice of finding somewhere they want to live, and it provides a subsidy for them, and these are vouchers that are, I think, earmarked for individuals with disabilities.
Another program is the Veterans Housing Rehabilitation and Modification Pilot Program. There was notice of funding opportunity in 2021, providing grants to nonprofits to rehabilitate or modify residences of low-income veterans with disabilities.
So, for these programs that I talked about, the goal is to provide housing or assist in providing housing for individuals with disabilities, but to provide the housing in community and integrated settings where people have, you know, the choice of where to live.
As I've discussed during the presentation, HUD's general programs are also designed to be accessible for individuals with disabilities, and there are requirements to have accessible units and provide reasonable accommodations and modifications for individuals with disabilities. HUD's programs include the Section 202 program, which is supportive housing for elderly persons. Continuum of Care program is homelessness assistance. HOME and community development block grants are monies that go to local jurisdictions for affordable housing and other programs. And also public housing programs, including public housing project-based vouchers and housing choice vouchers.
Another program I've worked on is the Rental Assistance Demonstration program, where public housing is converted to project-based voucher programs or project-based rental assistance, and the RAD Civil Rights Notice, which was published in 2016, includes a lot of civil rights requirements, including that if the subsidy is transferred to any location, that the property needs to be accessible for individuals with disabilities and cannot be located in an area of minority concentration.
And HUD also does front-end civil rights reviews when these types of convergence are proposed to ensure that the buildings still have enough accessible units, and that the buildings maintain their veteran sizes and other requirements.
So I think this is my last slide. I listed some resources that might be useful. There is HUD's statement on Olmstead, there are short statements -- joint statements between HUD and the Justice Department on reasonable modifications, reasonable accommodations, and in 2020, HUD issued a notice on assistance animals.
I also listed my e-mail address if people want to ask follow-up questions or discuss anything, I'm happy to talk.
So if anyone has any questions, you can go ahead and put them in the chat, or you can unmute yourself and ask it. I'm happy to hear anyone's voucher questions. Or if people are done, we can always end a little bit early and have some time before the next session.
DAVID PRAGER: This is David Prager. Good to see you, Shira. I have a question about proscribing a higher amount of accessible units. How would HUD go about that analysis of determining whether a higher number of accessible units is needed in any particular jurisdiction?
SHIRA GORDON: I'm not totally sure, and I think I would need to look a little bit more closely or talk to my colleagues who worked on the Los Angeles case. It might be the situation where it might be more likely to require a higher percentage if you're talking about specific... that if there's a housing authority that has a lack of accessible units, that maybe when they build, if they require new buildings, those would have a higher percentage. And otherwise, I think you can look at population data, HUD, I think, has data on the percentages of people in a locality with different types of disabilities. So I'm not totally sure how often that has happened in the past. If we issue an updated notice to the 504 regulations, that would be something we would be curious about, whether people think there should be a higher percentage than 5%/2%, or what situations would make sense to potentially require a higher percentage.
I saw the question from Alex about Section 811 and supportive housing. For programmatic work, I'm not totally sure -- I'm curious, you said your state is making major investments in supportive housing. I'm curious whether... whether those are under the Section 811 program or not. And actually, if you could clarify what you mean by, um, that supportive housing but not necessarily disability housing.
ALEX: My question is related to, my state is, I don't know exactly the details, but they've announced a lot of investment in supportive housing, but there's a lot of concern in our community that it's focused on people receiving services and not necessarily the population of people in general that need accessible housing. And so I think in your present -- towards the end there, you mentioned that Section 811 wasn't necessarily tied to people receiving the supportive services. So that's what I was curious in learning more about.
SHIRA GORDON: Yeah, something I haven't worked too much on, but I can also, if you do want to follow up, if you do have questions, I mean, I think -- it's basically my understanding that the program involves providing supportive services, but because people have a choice whether or not to use the services, that they can't be required. And I don't -- in terms of how people would secure units in the programs, I think the programs go to a nonprofit, then it would be a question of getting on their waiting list and applying, or if it goes more to a state or local community development organization, or that type of thing. It might be a question of contacting them. So I'm not totally sure -- I think they don't necessarily go through public housing authorities. But it can be -- I don't know if they would share a waiting list with a public housing authority or that kind of thing.
And if other people in the group know more about this, feel free to chime in! I think we can wrap up, unless people have any other questions or want to discuss anything. But thanks, everyone, for coming. I enjoyed talking with you!
BETH HIRST: Thank you, everyone. I'll end the session now.